In addition to the tables in the back of this publication, this publication contains discussions of the exemptions from tax and certain other effects of the tax treaties on the following types of income.

1. Pay for certain personal services performed in the United States.
2. Pay of a professor, teacher, or researcher who teaches or performs research in the United States for a limited time.
3. Amounts received for maintenance and studies by a foreign student or apprentice who is here for study or experience.
4. Wages, salaries, and pensions paid by a foreign government.

Personal Services Income

Pay for certain personal services performed in the United States is exempt from U.S. income tax if you are a resident of one of the countries discussed below, if you are in the United States for a limited number of days and if you meet certain other conditions. For this purpose, the word "day" means a day during any part of which you are physically present in the United States.

Terms defined. Several terms appear in many of the discussions that follow. The exact meanings of the terms are determined by the particular tax treaty under discussion; thus, the meanings vary among treaties. The definitions that follow are, therefore, general definitions that may not give the exact meaning intended by a particular treaty.

The terms fixed base and permanent establishment generally mean a fixed place of business, such as an office, a factory, a warehouse, or a mining site, through which an enterprise carries on its business.

The term borne by generally means having ultimate financial accounting responsibility for or providing the monetary resources for an expenditure or payment, even if another entity in another location actually made the expenditure or payment.

Australia

Income that residents of Australia receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States during the tax year is exempt from U.S. income tax if the residents:

1. Are in the United States for no more than 183 days during the tax year, and
2. Do not have a fixed base regularly available to them in the United States for the purpose of performing the services.

If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base.

Pay that residents of Australia receive for labor or personal services performed in the United States as employees (dependent personal services), including services as a director of a company, is exempt from U.S. income tax if:

1. The residents are in the United States for no more than 183 days during the tax year,
2. The pay is paid by, or on behalf of, an employer or company that is not a resident of the United States, and
3. The pay is not deductible in determining the taxable income of the trade or business of the employer (or company) in the United States.

These exemptions do not apply to public entertainers (such as theater, motion picture, radio, or television entertainers, musicians and athletes) from Australia who earn more than $10,000 in gross receipts, including reimbursed expenses, from their entertainment activities in the United States during the tax year.

Austria

Income that residents of Austria receive for personal services as independent contractors or self-employed individuals (independent personal services) in the United States is exempt from U.S. income tax if they do not have a fixed base regularly available to them in the United States for performing the services. If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base.

Income that residents of Austria receive for services performed in the United States as employees (dependent personal services) is exempt from U.S. income tax if the residents meet the following requirements:

1. They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year,
2. Their income is paid by, or on behalf of, an employer who is not a U.S. resident, and
3. Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States.

These exemptions do not apply to public entertainers (such as theater, motion picture, radio, or television entertainers, musicians and athletes) from Austria who earn more than $20,000 in gross receipts, including reimbursed expenses, from their entertainment activities in the United States during the tax year.

Income received by a resident of Austria for services performed as an employee and member of the regular complement of a ship or aircraft operated in international traffic is exempt from U.S. income tax.

Former treaty. For 1999, you can elect to apply the old treaty in its entirety. The provisions for personal service are as follows.

Income that residents of Austria receive for labor or personal services (including practicing liberal professions and performing services as a director) performed in the United States is exempt from U.S. income tax if they are temporarily in the United States for no more than 183 days during the tax year and the income is not more than $3,000.

Income, regardless of amount, received by residents of Austria who are temporarily in the United States for no more than 183 days during the tax year is also exempt from U.S. income tax if it is received for labor or personal services performed as an employee of, or under contract with, a natural person who is a resident of Austria or an Austrian corporation, and it is borne by that person or corporation.

Barbados

Income that residents of Barbados receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States during the tax year is exempt from U.S. income tax if the residents:

1. Are in the United States for no more than 89 days during the tax year,
2. Earn net income for independent services provided to U.S. residents that is not more than $5,000 (there is no dollar limit if the contractors are not U.S. residents), and
3. Do not have a regular base available in the United States for performing the services.

If they have a regular base available in the United States but otherwise meet the conditions for exemption, they are taxed only on the income attributable to the regular base.

Income that residents of Barbados receive for personal services performed in the United States as employees (dependent personal services) is exempt from U.S. tax if the residents meet four requirements:

1. They are in the United States for no more than 183 days during the calendar year,
2. The income earned in the calendar year in the United States is not more than $5,000,
3. Their income is paid by or for an employer who is not a U.S. resident, and
4. The income is not borne by a permanent establishment or regular base of the employer in the United States.

Income of a Barbadian resident from employment as a member of the regular complement of a ship or aircraft operated in international traffic is exempt from U.S. tax.

These exemptions do not apply to Barbadian resident public entertainers (such as theater, motion picture, radio, or television artists, musicians, or athletes) who receive gross receipts of more than $250 per day or $4,000 in the tax year, not including reimbursed expenses, from their entertainment activities in the United States. However, the exemptions do apply regardless of these limits on gross receipts if the entertainer's visit to the United States is substantially supported by Barbadian public funds or if the entertainer's services are provided to a nonprofit organization.

Belgium

Income that residents of Belgium receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States during the tax year is exempt from U.S. income tax if the residents:

1. Are present in the United States less than 183 days during the tax year, and
2. Do not maintain a fixed base in the United States for a period or periods that total more than 182 days during the tax year.

If they do not meet condition (2), they are taxed on the income attributed to the base.

The exemption for independent personal services does not apply to individuals who are public entertainers (theater, motion picture, or television artists, musicians, or athletes), if they are in the United States for more than 90 days during the tax year or if their pay for services as public entertainers is more than $3,000.

Income that residents of Belgium receive for labor or personal services performed in the United States as employees (dependent personal services), including services as an officer of a corporation, is exempt from U.S. income tax if the residents meet three requirements:

1. They are present in the United States less than 183 days during the tax year,
2. They are employees of a resident of Belgium or of a permanent establishment in Belgium, and
3. Their income is not borne by a permanent establishment that the employer has in the United States.

Income for services performed by an individual as an employee aboard a ship or an aircraft registered in Belgium and operated by a resident of Belgium in international traffic is exempt from U.S. tax if the individual is a member of the regular complement of the ship or aircraft.

These exemptions do not apply to fees received by a resident of Belgium for services performed as a director of a U.S. corporation if the fees are treated as a distribution of profits and cannot be taken as a deduction by the corporation.

Canada

Income that residents of Canada receive for personal services as independent contractors or self-employed individuals (independent personal services) that they perform during the tax year in the United States (except as public entertainers) is exempt from U.S. tax if they do not have a fixed base regularly available to them in the United States for performing the services. If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base.

Income that residents of Canada receive for personal services performed as employees (dependent personal services) in the United States (except as public entertainers) is exempt from U.S. tax if it is not more than $10,000 for the year. If it is more than $10,000 for the year, it is exempt only if:

1. The residents are present in the United States for no more than 183 days during the calendar year, and
2. The income is not borne by a U.S. resident employer or by a permanent establishment or fixed base of an employer in the United States.

These exemptions do not apply to public entertainers (such as theater, motion picture, radio, or television artists, musicians, or athletes) from Canada who derive more than $15,000 in gross receipts, including reimbursed expenses, from their entertainment activities in the United States during the calendar year. However, the exemptions do apply, regardless of this $15,000 limit, to athletes participating in team sports in leagues with regularly scheduled games in both Canada and the United States.

Pay received by a resident of Canada for employment regularly done in more than one country on a ship, aircraft, motor vehicle, or train operated by a Canadian resident is exempt from U.S. tax.

China, People's Republic of

Income that residents of the People's Republic of China receive for personal services as independent contractors or self-employed individuals (independent personal services) that they perform during the tax year in the United States (except as athletes or public entertainers) is exempt from U.S. income tax if the residents:

1. Are present in the United States for no more than 183 days in the calendar year, and
2. Do not have a fixed base regularly available in the United States for performing the services.

If they have a fixed base available in the United States, they are taxable on the income attributable to the fixed base.

Pay received by residents of the People's Republic of China for services performed as employees (dependent personal services) in the United States (except as athletes or public entertainers) is exempt from U.S. tax if:

1. The residents are present in the United States for no more than 183 days in the calendar year,
2. The pay is paid by or for an employer who is not a U.S. resident, and
3. The pay is not borne by a permanent establishment or fixed base that the employer has in the United States.

These exemptions do not apply to directors' fees for service on the board of directors of a U.S. corporation.

These exemptions generally do not apply to income received as a public entertainer (such as a theater, motion picture, radio, or television artist, musician, or athlete). However, income of athletes or public entertainers from China participating in a cultural exchange program agreed upon by the U.S. and Chinese governments is exempt from U.S. tax.

Commonwealth of Independent States

Income that residents of a C.I.S. member receive for performing personal services in the United States is exempt from U.S. income tax if those residents are in the United States for no more than 183 days during the tax year.

Pay received by an employee who is a member of the regular complement of a ship or aircraft operated in international traffic by a C.I.S. member or a resident of a C.I.S. member is exempt from U.S. tax.

Cyprus

Income that residents of Cyprus receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States during the tax year is exempt from U.S. income tax if the residents:

1. Are present in the United States for less than 183 days in the tax year, and
2. Do not have a fixed base regularly available to them in the United States for performing the services.

If they have a fixed base available in the United States, they are taxable on the income attributable to the fixed base.

Pay received by residents of Cyprus from services performed as employees (dependent personal services), including services as an officer of a corporation, is exempt from U.S. income tax if:

1. The residents are in the United States for less than 183 days during the tax year,
2. The pay is paid by or for an employer who is not a U.S. resident, and
3. The pay is not borne by a permanent establishment, fixed base, or trade or business that the employer has in the United States.

Pay received by a Cyprus resident for performing personal services as an employee and member of the regular complement of a ship or aircraft operated in international traffic by a resident of Cyprus is exempt from U.S. tax.

These exemptions do not apply to Cyprus resident public entertainers (theater, motion picture, radio, or television artists, musicians, or athletes) who receive gross receipts of more than $500 per day or $5,000 for the tax year, not including reimbursed expenses, from their entertainment activities in the United States.

Directors' fees received by residents of Cyprus for service on the board of directors of a U.S. corporation are exempt from U.S. income tax to the extent of a reasonable fixed amount payable to all directors for each day of attendance at directors' meetings held in the United States.

Czech Republic

Income that residents of the Czech Republic receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States is exempt from U.S. income tax if the residents:

1. Are present in the United States for no more than 183 days in any 12-month period, and
2. Do not have a fixed base regularly available to them in the United States for performing the services.

If they have a fixed base available, they are taxed only on income attributable to the fixed base.

Income that residents of the Czech Republic receive for employment in the United States (dependent personal services) is exempt from U.S. income tax if the following three requirements are met:

1. The resident is present in the United States for no more than 183 days in any 12-month period,
2. The income is paid by, or on behalf of, an employer who is not a U.S. resident, and
3. The income is not borne by a permanent establishment or a fixed base that the employer has in the United States.

These exemptions do not apply to income residents of the Czech Republic receive as public entertainers (such as theater, motion picture, radio, or television artists, or musicians) or sportsmen if their gross receipts, including reimbursed expenses, are more than $20,000 during the tax year. Regardless of these limits, income of Czech entertainers and sportsmen is exempt from U.S. income tax if their visit to the United States is substantially supported by public funds of the Czech Republic, its political subdivisions, or local authorities, or the visit is made pursuant to a specific arrangement between the United States and the Czech Republic.

These exemptions do not apply to directors' fees and similar payments received by a resident of the Czech Republic as a member of the board of directors of a company that is a resident of the United States.

Income from employment as a member of the regular complement of a ship or aircraft operated by a Czech enterprise in international traffic is exempt from U.S. income tax.

Denmark

Income that residents of Denmark receive for labor or personal services (including practicing liberal professions) performed in the United States is exempt from U.S. income tax if they are temporarily in the United States for no more than 90 days during the tax year and their pay is not more than $3,000.

All income for labor or personal services that residents of Denmark perform as employees of, or under contract with, a resident, corporation, or other entity of Denmark is exempt from U.S. income tax if they are in the United States for no more than 180 days during the tax year.

Egypt

Income that residents of Egypt receive for performing personal services as independent contractors or as self-employed individuals (independent personal services) in the United States during the tax year is exempt from U.S. income tax if they are in the United States for no more than 89 days during the tax year.

Income that residents of Egypt receive for labor or personal services performed in the United States as employees (dependent personal services), including income for services performed by an officer of a corporation or company, is exempt from U.S. income tax if the residents meet four requirements:

1. They are in the United States for no more than 89 days during the tax year,
2. They are employees of a resident of, or a permanent establishment in, Egypt,
3. Their income is not borne by a permanent establishment that the employer has in the United States, and
4. Their income is subject to Egyptian tax.

Pay received by a resident of Egypt who is an employee and member of the regular complement of a ship or an aircraft operated in international traffic by a resident of Egypt is exempt.

These exemptions do not apply to Egyptian resident public entertainers (theater, motion picture, radio, or television artists, musicians, or athletes), who earn income for services as public entertainers (both independent and dependent personal services) if the gross amount of the income is more than $400 for each day they are in the United States performing the services.

Estonia

Income that residents of Estonia receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States is exempt from U.S. income tax if the residents:

1. Are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year, and
2. Do not have a fixed base regularly available to them in the United States for performing the services.

If they have a fixed base available, they are taxed on the income attributable to the fixed base.

Income that residents of Estonia receive for services performed in the United States as employees (dependent personal services) is exempt from U.S. income tax if the following requirements are met:

1. The resident is in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year,
2. The income is paid by, or on behalf of, an employer who is not a U.S. resident, and
3. The income is not borne by a permanent establishment or a fixed base that the employer has in the United States.

These exemptions do not apply to directors' fees and similar payments received by a resident of Estonia as a member of the board of directors or similar body of a company that is a U.S. resident.

Income from employment as a member of the regular complement of a ship or an aircraft operated by an Estonian enterprise in international traffic is exempt from U.S. income tax.

These exemptions do not apply to income residents of Estonia receive as public entertainers (such as theater, motion picture, radio, or television artists, or musicians) or sportsmen if their gross receipts, including reimbursed expenses, are more than $20,000 for their personal activities in the United States during the tax year. Regardless of these limits, income of Estonian entertainers or athletes is exempt from U.S. income tax if their visit to the United States is wholly or mainly supported by public funds of Estonia, its political subdivisions, or local authorities.

Finland

Income that residents of Finland receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States is exempt from U.S. income tax if they do not have a fixed base regularly available to them in the United States for performing the services. If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base.

Income that residents of Finland receive for labor or personal services performed in the United States as employees (dependent personal services) is exempt from U.S. income tax if the residents meet three requirements:

1. They are in the United States for no more than 183 days during any 12-month period,
2. Their income is paid by, or on behalf of, an employer who is not a resident of the United States, and
3. Their income is not borne by a permanent establishment, fixed base, or trade or business that the employer has in the United States.

Income received for performing personal services as an employee and member of the regular complement of a ship or aircraft operated in international traffic by a resident of Finland is exempt from U.S. tax.

These exemptions do not apply to income residents of Finland receive as public entertainers or sportsmen if the gross income, including reimbursed expenses, is more than $20,000 for their personal activities in the United States during the calendar year.

France

Income that residents of France receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States is exempt from U.S. income tax if they do not have a fixed base regularly available to them in the United States for performing the services. If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base.

Income that residents of France receive for labor or personal services performed in the United States as employees (dependent personal services) is exempt from U.S. income tax if the residents meet three requirements:

1. They are in the United States for no more than 183 days in any 12-month period,
2. Their income is paid by, or on behalf of, an employer who is not a resident of the United States, and
3. Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States.

Income for services performed by a resident of France as an employee and member of the regular complement of a ship or an aircraft operated in international traffic is exempt from tax in the United States.

These exemptions do not apply to public entertainers (such as theater, motion picture, radio, or television artists, musicians), or sportsmen from France who earn more than $10,000 in gross receipts, including reimbursed expenses, from their entertainment activities in the United States during the tax year. Regardless of these limits, income of French entertainers or sportsmen is exempt from U.S. tax if their visit is principally supported by public funds of France.

These exemptions do not apply to directors' fees and similar payments received by a resident of France as a member of the board of directors of a company that is a resident of the United States.

Germany

Income that residents of Germany receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States is exempt from U.S. income tax if the income is not attributable to a fixed base regularly available in the United States.

Income that residents of Germany receive for labor or personal services performed in the United States as employees (dependent personal services) is exempt from U.S. tax if the residents meet three requirements:

1. They are in the United States for no more than 183 days during the calendar year,
2. The income is paid by, or on behalf of, an employer who is not a resident of the United States, and
3. The income is not borne by a permanent establishment or a fixed base that the employer has in the United States.

Pay received by a resident of Germany for services performed as an employee and member of the regular complement of a ship or aircraft operated in international traffic is exempt from U.S. tax.

These exemptions do not apply to directors' fees and other similar payments received by a resident of Germany for services performed in the United States as a member of the board of directors of a company resident in the United States.

These exemptions do not apply to income residents of Germany receive as public entertainers (such as theater, motion picture, radio or television artists, or musicians) or athletes if their gross receipts, including reimbursed expenses, are more than $20,000 during the calendar year. Regardless of these limits, income of German entertainers or athletes is exempt from U.S. tax if their visit to the United States is substantially supported by public funds of Germany, its political subdivisions, or local authorities.

Greece

Income that residents of Greece receive for labor or personal services (including practicing liberal and artistic professions) is exempt from U.S. income tax if they are in the United States for no more than 183 days during the tax year and the pay is not more than $10,000. The pay, regardless of amount, is exempt from U.S. income tax if it is for labor or personal services performed as employees of, or under contract with, a resident of Greece or a Greek corporation or other entity of Greece, and if the residents are in the United States for no more than 183 days during the tax year.

Hungary

Income that residents of Hungary receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States during the tax year is exempt from U.S. tax if the residents:

1. Are in the United States for no more than 183 days during the tax year, and
2. Do not have a fixed base regularly available in the United States.

If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base.

Income that residents of Hungary receive for labor or personal services performed in the United States as employees (dependent personal services) is exempt from U.S. income tax if the residents meet three requirements:

1. They are in the United States for no more than 183 days during the tax year,
2. Their income is paid by or on behalf of an employer who is not a resident of the United States, and
3. Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States.

Pay received by an employee who is a member of the regular complement of a ship or aircraft operated by a resident of Hungary in international traffic is also exempt.

Iceland

Income that residents of Iceland receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States during the tax year is exempt from U.S. income tax if the residents:

1. Are present in the United States for no more than 182 days during the tax year, and
2. Do not maintain a fixed base in the United States for a period or periods totaling more than 182 days during the tax year.

If they do not meet condition (2), they are taxed on the income that is attributable to the fixed base.

This exemption does not apply to residents of Iceland who are public entertainers (theater, motion picture, or television artists, musicians, or athletes) if they are in the United States for more than 90 days during the tax year or their pay for services as public entertainers is more than $100 per day.

Income that residents of Iceland receive for labor or personal services performed in the United States as employees (dependent personal services) is exempt from U.S. income tax if the employees meet three requirements:

1. They are in the United States for no more than 182 days during the tax year,
2. They are employees of a resident of Iceland or of a permanent establishment of a resident of a state other than Iceland if the permanent establishment is located in Iceland, and
3. Their income is not borne by a permanent establishment that the employer has in the United States.

Income for services performed by an employee aboard a ship or an aircraft operated by a resident of Iceland in international traffic or in fishing on the high seas is exempt from U.S. tax if the individual is a member of the regular complement of the ship or aircraft.

India

Income that residents of India receive for performing personal services in the United States during the tax year as independent contractors or self-employed individuals (independent personal services) is exempt from U.S. income tax if the residents:

1. Are present in the United States for no more than 89 days during the tax year, and
2. Do not have a fixed base regularly available to them in the United States for performing the services.

If they have a fixed base available, they are taxed only on income attributable to the fixed base.

Income that residents of India receive for personal services performed in the United States as employees (dependent personal services) is exempt from U.S. income tax if the residents meet three requirements:

1. They are present in the United States for no more than 183 days during the tax year,
2. The income is paid by, or on behalf of, an employer who is not a resident of the United States, and
3. The income is not borne by a permanent establishment, fixed base, or trade or business the employer has in the United States.

These exemptions do not apply to directors' fees and similar payments received by an Indian resident as a member of the board of directors of a company that is a U.S. resident.

Pay received by a resident of India for services performed as an employee aboard a ship or aircraft operated by an Indian enterprise in international traffic is exempt from U.S. tax.

These exemptions do not apply to income residents of India receive as public entertainers (such as theater, motion picture, radio, or television artists, or musicians) or athletes if their net income is more than $1,500 during the tax year for their entertainment activities in the United States. Regardless of this limit, the income of Indian entertainers and athletes is exempt from U.S. tax if their visit to the United States is wholly or substantially supported from the public funds of the Indian Government, its political subdivisions, or local authorities.

Indonesia

Income that residents of Indonesia receive for performing personal services as individual contractors or self-employed individuals (independent personal services) in the United States during the tax year is exempt from U.S. income tax if the residents:

1. Are present in the United States for no more than 119 days during any consecutive 12-month period, and
2. Do not have a fixed base regularly available to them in the United States for performing the services.

If they have a fixed base available, they are taxed only on the income attributable to the fixed base.

Income that residents of Indonesia receive for personal services performed in the United States as employees (dependent personal services) is exempt from U.S. income tax if the residents meet three requirements:

1. They are present in the United States no more than 119 days during any consecutive 12-month period,
2. The income is paid by, or on behalf of, an employer who is not a resident of the United States, and
3. The income is not borne or reimbursed by a permanent establishment the employer has in the United States.

Pay received by an individual for services performed as an employee aboard a ship or aircraft operated by an Indonesian resident in international traffic is exempt from U.S. tax if the individual is a member of the regular complement of the ship or aircraft.

These exemptions do not apply to income residents of Indonesia receive as public entertainers (such as theater, motion picture, radio, or television artists, or musicians) or athletes if their gross receipts, including reimbursed expenses, are more than $2,000 during any consecutive 12-month period. Regardless of these limits, income of Indonesian entertainers and athletes is exempt from U.S. tax if their visit to the United States is substantially supported or sponsored by the Indonesian Government and the Indonesian competent authority certifies that the entertainers or athletes qualify for this exemption.

Ireland

Income that residents of Ireland receive for personal services as independent contractors or self-employed individuals (independent personal services) in the United States is exempt from U.S. income tax if they do not have a fixed base regularly available to them in the United States for performing the services. If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base.

Income that residents of Ireland receive for services performed in the United States as employees (dependent personal services) is exempt from U.S. income tax if the residents meet the following requirements:

1. They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year,
2. Their income is paid by, or on behalf of, an employer who is not a U.S. resident, and
3. Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States.

These exemptions do not apply to directors' fees and similar payments received by a resident of Ireland as a member of the board of directors of a company that is a resident of the United States. However, amounts received for attending meetings in Ireland are not subject to U.S. income tax.

Income received by a resident of Ireland for services performed as an employee and member of the regular complement of a ship or aircraft operated in international traffic is exempt from U.S. income tax.

These exemptions do not apply to public entertainers (such as theater, motion picture, radio, or television entertainers, musicians and athletes) from Ireland who earn more than $20,000 in gross receipts, including reimbursed expenses, from their entertainment activities in the United States during the tax year.

Israel

Income that residents of Israel receive for performing personal services as independent contractors or as self-employed individuals (independent personal services) in the United States during the tax year is exempt from U.S. income tax if they are in the United States for no more than 182 days during the tax year.

Income that residents of Israel receive for labor or personal services performed in the United States as employees (dependent personal services), including income for services performed by an officer of a corporation or company, is exempt from U.S. income tax if the residents meet four requirements:

1. They are in the United States for no more than 182 days during the tax year,
2. They are employees of a resident of, or a permanent establishment in, Israel,
3. Their income is not borne by a permanent establishment that the employer has in the United States, and
4. Their income is subject to Israeli tax.

Generally, pay received by an employee of a resident of Israel for labor or personal services performed as a member of the regular complement of a ship or an aircraft operated in international traffic by a resident of Israel is exempt.

These exemptions do not apply to income that residents of Israel receive as public entertainers (such as theater, motion picture, radio or television artists, musicians, or athletes), if the gross amount of the income is more than $400 for each day they are in the United States performing the services.

Italy

Income that residents of Italy receive for performing personal services in the United States during the tax year as independent contractors or self-employed individuals (independent personal services) is exempt from U.S. income tax if the residents:

1. Are present in the United States for no more than 183 days in the tax year, and
2. Do not have a fixed base regularly available to them in the United States for performing the services.

If they have a fixed base available, they are taxed only on the income attributable to the fixed base.

Income that residents of Italy receive for personal services performed in the United States as employees (dependent personal services) is exempt from U.S. income tax if:

1. The residents are present in the United States for not more than 183 days during the tax year,
2. The income is paid by or for an employer who is not a U.S. resident, and
3. The income is not borne by a permanent establishment or fixed base that the employer has in the United States.

Pay received by a resident of Italy from employment regularly exercised aboard a ship or aircraft operated by an Italian enterprise in international traffic is exempt from U.S. tax.

These exemptions do not apply to directors' fees and similar payments received by an Italian resident as a member of the board of directors of a company that is a U.S. resident.

These exemptions do not apply to income residents of Italy receive as public entertainers (such as theater, motion picture, radio, or television artists, musicians, or athletes) if they are present in the United States for more than 90 days during the tax year or their gross receipts, including reimbursed expenses, are more than $12,000 during the tax year for their entertainment activities in the United States.

Jamaica

Income that residents of Jamaica receive for the performance of personal services as independent contractors or self-employed individuals (independent personal services) in the United States during the tax year is exempt from U.S. income tax if the residents:

1. Are in the United States for no more than 89 days during the tax year,
2. Do not have a fixed base regularly available to them in the United States for performing their services, and
3. Earn net income for those services that is not more than $5,000 during the tax year if the income is from a U.S. contractor.

If they have a fixed base available in the United States, they are taxed only on the income that is attributable to the fixed base. There is no dollar limit for condition (3) if the contractor is from a country other than the United States.

Income that residents of Jamaica receive for personal services performed in the United States as employees (dependent personal services) is exempt from U.S. income tax if the residents meet four requirements:

1. They are in the United States for no more than 183 days during the tax year,
2. Their income is paid by or for an employer who is not a resident of the United States,
3. Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States, and
4. Their net income received for the services is not more than $5,000 during the tax year.

Pay received from employment as a member of the regular complement of a ship or an aircraft operated in international traffic by a Jamaican enterprise is exempt.

These exemptions do not apply to income that residents of Jamaica receive for performing services (both independent and dependent personal services) in the United States as entertainers, such as theater, motion picture, radio, or television artists, musicians, or athletes, if the gross receipts (excluding reimbursements for expenses) from the services are more than $400 a day or $5,000 for the tax year.

Directors' fees received by residents of Jamaica for services performed in the United States as members of boards of directors of U.S. corporations are exempt from U.S. tax if the fees (excluding reimbursed expenses) are not more than $400 per day for each day the directors are present in the United States to perform the services.

Japan

Income that residents of Japan receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States during the tax year is exempt from U.S. income tax if the residents:

1. Are present in the United States for no more than 183 days during the tax year, and
2. Do not maintain a fixed base in the United States for more than 183 days during the tax year.

If they do not meet condition (2), they are taxed on only the income attributable to the fixed base.

This exemption does not apply to residents of Japan who are public entertainers (theater, motion picture, or television artists, musicians, or athletes) if they are in the United States for more than 90 days during the tax year or their pay (excluding reimbursed travel expenses) for services as public entertainers is more than $3,000 during the tax year.

Income that residents of Japan receive for labor or personal services performed in the United States as employees (dependent personal services), including pay received by an officer or a member of the board of directors of a corporation, is exempt from U.S. income tax if the residents meet three requirements:

1. They are in the United States for no more than 183 days during the tax year,
2. They are employees of a resident of Japan or of a permanent establishment of a resident of a state other than Japan if the permanent establishment is located in Japan, and
3. Their income is not borne by a permanent establishment that the employer has in the United States.

However, the exemption does not apply in certain cases in which the employee owns stock of the employer or is a member of the employer's board of directors.

Pay received from employment as a member of the regular complement of a ship or aircraft operated in international traffic by a resident of Japan is exempt.

Kazakstan

Income that residents of Kazakstan receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States is exempt from U.S. income tax if:

1. The residents are in the United States for no more than 183 days in any consecutive 12-month period, and
2. The income is not attributable to a fixed base in the United States which is regularly available to the residents.

If the residents have a fixed base available, they are taxed only on the income attributable to the fixed base.

Income that residents of Kazakstan receive for employment in the United States (dependent personal services) is exempt from U.S. income tax if the following three requirements are met:

1. The resident is in the United States for no more than 183 days in any 12-month period,
2. The income is paid by, or on behalf of, an employer who is not a resident of the United States, and
3. The income is not borne by a permanent establishment or a fixed base that the employer has in the United States.

Income from employment as a member of the regular complement of a ship or aircraft operated in international traffic is exempt from U.S. tax.

These exemptions do not apply to directors' fees and similar payments received by a resident of Kazakstan as a member of the board of directors or similar body of a company that is a U.S. resident.

Korea, Republic of

Income that residents of the Republic of Korea receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States during the tax year is exempt from U.S. tax if the residents:

1. Are in the United States for no more than 182 days during the tax year,
2. Earn income for those services that is not more than $3,000 during the tax year, and
3. Do not maintain a fixed base in the United States for more than 182 days during the tax year.

If they maintain a fixed base in the United States for more than 182 days, they are taxed on the income attributable to the fixed base.

Income that residents of Korea receive for labor or personal services performed in the United States as employees (dependent personal services), including pay for services performed as an officer of a corporation, is exempt from U.S. tax if the residents meet four requirements:

1. They are in the United States for no more than 182 days during the tax year,
2. They are employees of a resident of Korea or of a permanent establishment maintained in Korea,
3. Their compensation is not borne by a permanent establishment that the employer has in the United States, and
4. Their income for those services is not more than $3,000.

Pay received by employees who are members of the regular complement of a ship or aircraft operated by a resident of Korea in international traffic is exempt.

Latvia

Income that residents of Latvia receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States is exempt from U.S. income tax if the residents:

1. Are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year, and
2. Do not have a fixed base regularly available to them in the United States for performing the services.

If they have a fixed base available, they are taxed only on the income attributable to the fixed base.

Income that residents of Latvia receive for services performed in the United States as employees (dependent personal services) is exempt from U.S. income tax if the following requirements are met:

1. The resident is in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year,
2. The income is paid by, or on behalf of, an employer who is not a U.S. resident, and
3. The income is not borne by a permanent establishment or a fixed base that the employer has in the United States.

These exemptions do not apply to directors' fees and similar payments received by a resident of Latvia as a member of the board of directors or similar body of a company that is a U.S. resident.

Income from employment as a member of the regular complement of a ship or an aircraft operated by a Latvian enterprise in international traffic is exempt from U.S. income tax.

These exemptions do not apply to income residents of Latvia receive as public entertainers (such as theater, motion picture, radio, or television artists, or musicians) or sportsmen if their gross receipts, including reimbursed expenses, are more than $20,000 for their personal activities in the United States during the tax year. Regardless of these limits, income of Latvian entertainers or athletes is exempt from U.S. income tax if their visit to the United States is wholly or mainly supported by public funds of Latvia, its political subdivisions, or local authorities.

Lithuania

Income that residents of Lithuania receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States is exempt from U.S. income tax if the residents:

1. Are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year, and
2. Do not have a fixed base regularly available to them in the United States for performing the services.

If they have a fixed base available, they are taxed only on the income attributable to the fixed base.

Income that residents of Lithuania receive for services performed in the United States as employees (dependent personal services) is exempt from U.S. income tax if the following requirements are met:

1. The resident is in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year,
2. The income is paid by, or on behalf of, an employer who is not a U.S. resident, and
3. The income is not borne by a permanent establishment or a fixed base that the employer has in the United States.

These exemptions do not apply to directors' fees and similar payments received by a resident of Lithuania as a member of the board of directors or similar body of a company that is a U.S. resident.

Income from employment as a member of the regular complement of a ship or an aircraft operated by a Lithuanian enterprise in international traffic is exempt from U.S. income tax.

These exemptions do not apply to income residents of Lithuania receive as public entertainers (such as theater, motion picture, radio, or television artists, or musicians) or sportsmen if their gross receipts, including reimbursed expenses, are more than $20,000 for their personal activities in the United States during the tax year. Regardless of these limits, income of Lithuanian entertainers or athletes is exempt from U.S. income tax if their visit to the United States is wholly or mainly supported by public funds of Lithuania, its political subdivisions, or local authorities.

Luxembourg

Income (other than corporate directors' fees) that residents of Luxembourg receive for labor or personal services performed in the United States during the tax year is exempt from U.S. income tax if the residents are in the United States for no more than 180 days during the tax year and the income is not more than $3,000.

All income (other than corporate directors' fees) that residents of Luxembourg receive for labor or personal services performed in the United States as an employee is exempt from U.S. income tax if:

1. The residents are in the United States for no more than 180 days during the tax year, and
2. The income is borne by an employer that is a resident or corporation of Luxembourg, or a permanent establishment of a U.S. enterprise in Luxembourg.

Mexico

Income that residents of Mexico receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States is exempt from U.S. income tax if the residents:

1. Are in the United States for no more than 183 days in a 12-month period, and
2. Do not have a fixed base that they regularly use for performing the services.

If they have a fixed base available, they are taxed only on income attributable to the fixed base.

Income that residents of Mexico receive for employment in the United States (dependent personal services) is exempt from U.S. tax if the following three requirements are met:

1. The resident is present in the United States for no more than 183 days in a 12-month period,
2. The income is paid by, or on behalf of, an employer who is not a resident of the United States, and
3. The income is not borne by a permanent establishment or fixed base that the employer has in the United States.

These exemptions do not apply to director's fees and similar payments received by a resident of Mexico for services performed outside Mexico as a director or overseer of a company that is a U.S. resident.

These exemptions do not apply to income residents of Mexico receive as public entertainers (such as theater, motion picture, radio, or television artists, or musicians) or athletes if the income, including reimbursed expenses, is more than $3,000 during the tax year for their entertainment activities in the United States. This includes income from activities performed in the United States relating to the entertainer or athlete's reputation, such as endorsements of commercial products. Regardless of this limit, the income of Mexican entertainers and athletes is exempt from U.S. tax if their visit to the United States is substantially supported by public funds of Mexico, its political subdivisions, or local authorities.

Morocco

Income that residents of Morocco receive for performing personal services as independent contractors or as self-employed persons (independent personal services) in the United States during the tax year is exempt from U.S. income tax if the residents:

1. Are in the United States for no more than 182 days during the tax year,
2. Do not maintain a fixed base in the United States for more than 89 days during the tax year, and
3. Earn total income for those services that is not more than $5,000.

If they have a fixed base in the United States for more than 89 days, they are taxed only on the income attributable to the fixed base.

Income that residents of Morocco receive for labor or personal services performed in the United States as employees (dependent personal services) is exempt from U.S. income tax if the residents meet three requirements:

1. They are in the United States for less than 183 days during the tax year,
2. They are employees of a resident of Morocco or of a permanent establishment of a resident of a country other than Morocco if the permanent establishment is located in Morocco, and
3. Their income is not borne by a permanent establishment that the employer has in the United States.

Compensation received for services performed by a member of the board of directors of a corporation does not qualify for this exemption.

Income received by an individual for performing labor or personal services as an employee aboard a ship or an aircraft operated in international traffic by a Moroccan resident is exempt from U.S. income tax if the individual is a member of the regular complement of the ship or aircraft.

These exemptions do not apply to income received for services (both independent and dependent personal services) performed in the United States by professional entertainers, including theater, film, radio, and television performers, musicians, and athletes, unless the services are performed by, or for the account of, a Moroccan nonprofit organization.

Netherlands

Income that residents of the Netherlands receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States is exempt from U.S. income tax if the income is not attributable to a fixed base in the United States that is regularly available for performing the services.

Income that residents of the Netherlands receive for employment in the United States (dependent personal services) is exempt from U.S. income tax if the following three requirements are met:

1. The resident is in the United States for no more than 183 days during the tax year,
2. The income is paid by, or on behalf of, an employer who is not a U.S. resident, and
3. The income is not borne by a permanent establishment or fixed base the employer has in the United States.

Income received by a Netherlands resident for employment as a member of the regular complement of a ship or aircraft operated in international traffic is exempt from U.S. tax.

These exemptions do not apply to directors' fees and other similar payments received by a resident of the Netherlands for services performed outside the Netherlands as a member of the board of directors of a company resident in the United States.

These exemptions do not apply to income residents of the Netherlands receive as public entertainers (such as theater, motion picture, radio, or television artists, or musicians) or athletes if the gross income, including reimbursed expenses, is more than $10,000.

New Zealand

Income that residents of New Zealand receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States in any tax year is exempt from U.S. income tax if the residents:

1. Are present in the United States for no more than 183 days during any consecutive 12-month period, and
2. Do not have a fixed base regularly available to them in the United States for performing the services.

If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base.

Income that residents of New Zealand receive for labor or personal services performed in the United States as employees (dependent personal services) is exempt from U.S. income tax if the residents meet these requirements:

1. They are present in the United States for no more than 183 days in any consecutive 12-month period,
2. Their income is paid by or on behalf of an employer that is not a resident of the United States, and
3. Their income is not borne by a permanent establishment or fixed base of the employer in the United States.

Pay received by a New Zealand resident as an employee and member of the regular complement of a ship or aircraft operated in international traffic is exempt from U.S. tax.

The exemption from U.S. tax on income from both independent and dependent personal services does not apply to public entertainers (artists, athletes, etc.) from New Zealand who earn more than $10,000 in gross receipts, including reimbursed expenses, from their entertainment activities in the United States during the tax year.

Norway

Income that residents of Norway receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States during the tax year is exempt from U.S. income tax if the residents:

1. Are present in the United States for no more than 182 days during the tax year, and
2. Do not maintain a fixed base in the United States for more than 182 days during the tax year.

If they do not meet requirement (2), they are taxed only on the income attributable to the fixed base.

This exemption does not apply to residents of Norway who are public entertainers (theater, motion picture, or television artists, musicians, or athletes) if they are in the United States for more than 90 days during the tax year or their pay for services as public entertainers is more than $10,000 during the tax year.

Income that residents of Norway receive for labor or personal services performed in the United States as employees (dependent personal services) is exempt from U.S. income tax if the residents meet three requirements:

1. They are in the United States less than 183 days during the tax year,
2. They are employees of a resident of Norway or of a permanent establishment of a resident of a state other than Norway if the permanent establishment is situated in Norway, and
3. Their income is not borne by a permanent establishment that the employer has in the United States.

However, the exemption does not apply to a resident of Norway who performs services as an employee aboard a ship or an aircraft operated by a United States resident in international traffic or in fishing on the high seas if the resident of Norway is a member of the regular complement of the ship or aircraft.

Pakistan

Residents of Pakistan who perform personal services (including professional services) for or on behalf of a resident of Pakistan while in the United States for no more than 183 days during the tax year are exempt from U.S. income tax on the income from the services if they are subject to Pakistani tax.

Philippines

Income that residents of the Philippines receive for performing personal services as independent contractors or as self-employed individuals (independent personal services) in the United States during the tax year is exempt from U.S. income tax if the residents:

1. Are in the United States for no more than 89 days during the tax year,
2. Earn gross income for those services that is not more than $10,000 for the tax year if the income is from U.S. contractors, and
3. Do not have a fixed base regularly available to them in the United States for performing their services.

If they have a fixed base available in the United States, they are taxed only on the income attributable to the fixed base. There is no dollar limit for condition (2) if the contractor is a resident of a country other than the United States.

Income that residents of the Philippines receive for personal services performed in the United States as employees (dependent personal services) is exempt from U.S. income tax if the residents meet three requirements:

1. They are in the United States for no more than 89 days during the tax year,
2. They are employees of a resident of the Philippines or of a permanent establishment maintained in the Philippines, and
3. Their income is not borne by a permanent establishment that the employer has in the United States.

Pay received by an employee of a resident of the Philippines for personal services performed as a member of the regular complement of a ship or an aircraft operated in international traffic by a resident of the Philippines is exempt.

These exemptions do not apply to income residents of the Philippines receive for performing services (both independent and dependent personal services) in the United States as entertainers, such as theater, motion picture, radio, or television artists, musicians, or athletes, if the income is more than $100 a day or $3,000 for the tax year. Regardless of these limits, income of Philippine entertainers is exempt from U.S. tax if their visit to the United States is substantially supported or sponsored by the Philippine Government and the entertainers are certified as qualified for this exemption by the Philippine competent authority.

Poland

Income that residents of Poland receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States is exempt from U.S. income tax if they are in the United States for no more than 182 days during the tax year.

Income that residents of Poland receive for labor or personal services performed as employees (dependent personal services), including services performed by an officer of a corporation or company, in the United States during the tax year is exempt from U.S. income tax if the residents meet three requirements:

1. They are in the United States for no more than 182 days during the tax year,
2. Their income is paid by or on behalf of an employer who is not a U.S. resident, and
3. Their income is not borne by a permanent establishment that the employer has in the United States.

Pay received by employees who are members of the regular complement of a ship or aircraft operated by a resident of Poland in international traffic is exempt.

Portugal

Income that residents of Portugal receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States is exempt from U.S. income tax if the residents:

1. Are in the United States for no more than 182 days in any 12-month period, and
2. Do not have a fixed base regularly available to them in the United States for performing the activities.

If they have a fixed base available, they are taxed only on the income attributable to the fixed base.

Income that residents of Portugal receive for employment in the United States (dependent personal services) is exempt from U.S. income tax if the following three requirements are met:

1. The resident is in the United States for no more than 183 days in any 12-month period,
2. The income is paid by, or on behalf of, an employer who is not a U.S. resident, and
3. The income is not borne by a permanent establishment or fixed base that the employer has in the United States.

Income received by a resident of Portugal for employment as a member of the regular complement of a ship or aircraft operated in international traffic is exempt from U.S. tax.

These exemptions do not apply to income residents of Portugal receive as public entertainers (such as theater, motion picture, radio, or television artists, or musicians) or athletes if that income, including reimbursed expenses, is more than $10,000. The income of Portuguese entertainers and athletes is exempt from U.S. tax if their visit to the United States is substantially supported by public funds of Portugal or its political or administrative subdivisions.

These exemptions do not apply to directors' fees and similar payments received by a resident of Portugal for services performed outside of Portugal as a member of the board of directors of a company that is a resident of the United States.

Romania

Income that residents of Romania receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States during the tax year is exempt from U.S. income tax if the residents:

1. Are present in the United States for no more than 182 days during the tax year, and
2. Do not maintain a permanent establishment in the United States with which the income is effectively connected.

Income that residents of Romania receive for labor or personal services performed as employees (dependent personal services), including services performed by an officer of a corporation or company, in the United States during the tax year is exempt from U.S. income tax if the residents meet these requirements:

1. They are in the United States for no more than 182 days during the tax year,
2. They are employees of a resident of Romania or of a permanent establishment maintained in Romania by a resident of the United States, and
3. Their income is not borne by a permanent establishment that the employer has in the United States.

These exemptions do not apply to entertainers, such as theater, motion picture, radio, or television artists, musicians, or athletes, who are present in the United States for more than 90 days during the tax year (90 days or more if the entertainers are employees) or who earn gross income as entertainers in the United States of more than $3,000 during the tax year ($3,000 or more if they are employees). However, the exemptions do apply, without regard to the 90 day, $3,000 requirement, if the entertainers are present in the United States by specific arrangements between the United States and Romania.

Pay received by employees who are members of the regular complement of a ship or aircraft operated by a resident of Romania in international traffic is exempt.

Russia

Income that residents of Russia receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States is exempt from U.S. income tax if:

1. The residents are in the United States for no more than 183 days during the calendar year, or
2. The income is not attributable to a fixed base in the United States which is regularly available to the residents.

If the residents have a fixed base available, they are taxed only on the income attributable to the fixed base.

Income that residents of Russia receive for employment in the United States (dependent personal services) is exempt from U.S. income tax if the following three requirements are met:

1. The resident is in the United States for no more than 183 days during the calendar year,
2. The income is paid by, or on behalf of, an employer who is not a resident of the United States, and
3. The income is not borne by a permanent establishment or a fixed base that the employer has in the United States.

However, income from employment directly connected with a place of business that is not a permanent establishment is exempt if the resident is present in the United States not longer than 12 consecutive months. For this purpose, a place of business means a construction site, assembly or installation project, or drilling operation.

Income from employment as a member of the regular complement of a ship or aircraft operated in international traffic is exempt from U.S. tax.

Income from technical services directly connected with the application of a right or property giving rise to a royalty is exempt if those services are provided as part of a contract granting the use of the right or property.

These exemptions do not apply to directors' fees and similar payments received by a resident of Russia as a member of the board of directors or similar body of a company that is a U.S. resident.

Slovak Republic

Income that residents of the Slovak Republic receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States is exempt from U.S. income tax if the residents:

1. Are present in the United States for no more than 183 days in any 12-month period, and
2. Do not have a fixed base regularly available to them in the United States for performing the activities.

If they have a fixed base available, they are taxed only on income attributable to the fixed base.

Income that residents of the Slovak Republic receive for employment in the United States (dependent personal services) is exempt from U.S. income tax if the following three requirements are met:

1. The resident is present in the United States for no more than 183 days in any 12-month period,
2. The income is paid by, or on behalf of, an employer who is not a U.S. resident, and
3. The income is not borne by a permanent establishment or a fixed base that the employer has in the United States.

These exemptions do not apply to income residents of the Slovak Republic receive as public entertainers (such as theater, motion picture, radio, or television artists, or musicians) or sportsmen if their gross receipts, including reimbursed expenses, are more than $20,000 during the tax year. Regardless of these limits, income of Slovak entertainers and sportsmen is exempt from U.S. income tax if their visit to the United States is substantially supported by public funds of the Slovak Republic, its political subdivisions, or local authorities, or the visit is made pursuant to a specific arrangement between the United States and the Slovak Republic.

These exemptions do not apply to directors' fees and similar payments received by a resident of the Slovak Republic for services performed in the United States as a member of the board of directors of a company that is a resident of the United States.

Income from employment as a member of the regular complement of a ship or aircraft operated by a Slovak enterprise in international traffic is exempt from U.S. income tax.

South Africa

Income that residents of South Africa receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States is exempt from U.S. income tax if the residents:

1. Are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year, and
2. Do not have a fixed base regularly available to them in the United States for performing the services.

If they have a fixed base available, they are taxed only on income attributable to the fixed base.

Income that residents of South Africa receive for services performed in the United States as employees (dependent personal services) is exempt from U.S. income tax if the following requirements are met:

1. The resident is in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year,
2. The income is paid by, or on behalf of, an employer who is not a U.S. resident, and
3. The income is not borne by a permanent establishment or a fixed base that the employer has in the United States.

These exemptions do not apply to directors' fees and similar payments received by a resident of South Africa for services performed in the United States as a member of the board of directors of a company resident in the United States.

These exemptions do not apply to income residents of South Africa receive as public entertainers (such as theater, motion picture, radio or television artists, or musicians) or athletes if their gross receipts, including reimbursed expenses, are more than $7,500 during the tax year. Regardless of these limits, income of South African entertainers or athletes is exempt from U.S. income tax if their visit to the United States is wholly or mainly supported by public funds of South Africa, its political subdivisions, or local authorities.

Income received by a resident of South Africa for services performed as an employee and member of the complement of a ship or aircraft operated in international traffic is exempt from U.S. income tax.

Spain

Income that residents of Spain receive as independent contractors or self-employed individuals (independent personal services) in the United States is exempt from U.S. income tax if the residents do not have a fixed base available to them in the United States for performing the services. If they have a fixed base, they are taxed only on the income attributable to the fixed base.

Income that residents of Spain receive for personal services performed in the United States as employees (dependent personal services) is exempt from U.S. income tax if:

1. The residents are present in the United States no more than 183 days in any 12-month period,
2. The income is paid by, or on behalf of, an employer who is not a U.S. resident, and
3. The income is not borne by a permanent establishment or fixed base the employer has in the United States.

Pay received by employees who are members of a regular complement of a ship or aircraft operated in international traffic by a Spanish enterprise may be taxed by Spain.

These exemptions do not apply to public entertainers (such as theater, motion picture, radio, or television artists, or musicians) or athletes from Spain who earn more than $10,000 in income, including reimbursed expenses, from their entertainment activities in the United States during the tax year. Regardless of these limits, Spanish entertainers and athletes are exempt from U.S. tax if their visit to the United States is substantially supported by public funds of Spain, a political subdivision, or local authority.

Sweden

Income that residents of Sweden receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States during the tax year is exempt from U.S. income tax if they do not have a fixed base regularly available to them in the United States for performing the services. If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base.

Income that residents of Sweden receive for labor or personal services performed in the United States as employees (dependent personal services) is exempt from U.S. income tax if the residents meet three requirements:

1. They are in the United States for no more than 183 days during any consecutive 12-month period,
2. Their income is paid by, or on behalf of, an employer who is not a resident of the United States, and
3. Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States.

Income received by a resident of Sweden for employment as a member of the regular complement of a ship or aircraft operated in international traffic is exempt from U.S. tax.

These exemptions do not apply to income residents of Sweden receive as public entertainers (such as theater, motion picture, radio, or television artists, or musicians) or athletes if the gross income, including reimbursed expenses, is more than $6,000 for any 12-month period.

These exemptions do not apply to directors' fees received by a resident of Sweden for services performed outside of Sweden as a member of the board of directors of a company that is a resident of the United States.

Switzerland

Income that residents of Switzerland receive for personal services as independent contractors or self-employed individuals (independent personal services) that they perform during the tax year in the United States is exempt from U.S. income tax if they do not have a fixed base regularly available to them in the United States for performing the services. If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base.

Income that residents of Switzerland receive for services performed in the United States as employees (dependent personal services) is exempt from U.S. income tax if the residents meet the following requirements:

1. They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year,
2. Their income is paid by, or on behalf of, an employer who is not a U.S. resident, and
3. Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States.

These exemptions do not apply to directors' fees and similar payments received by a resident of Switzerland for services performed in the United States as a member of the board of directors of a company resident in the United States.

These exemptions do not apply to public entertainers (such as theater, motion picture, radio, or television entertainers, musicians and athletes) from Switzerland who earn more than $10,000 in gross receipts, including reimbursed expenses, from their entertainment activities in the United States during the tax year.

Income received by a resident of Switzerland for services performed as an employee and member of the regular complement of a ship or aircraft operated in international traffic is exempt from U.S. income tax.

Thailand

Income that residents of Thailand receive for performing personal services as independent contractors or as self-employed individuals (independent personal services) in the United States during the tax year is exempt from U.S. income tax if the residents:

1. Are in the United States for no more than 89 days during the tax year, and
2. Do not have a fixed base regularly available to them in the United States for performing their services.

If they have a fixed base available in the United States, they are taxed only on the income attributable to the fixed base.

This exemption does not apply if a resident of Thailand earns more than $10,000 for independent personal services and that income is paid by a U.S. resident or borne by a permanent establishment or fixed base in the United States.

Income that residents of Thailand receive for services performed in the United States as employees (dependent personal services) is exempt from U.S. income tax if the following requirements are met:

1. The resident is in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year,
2. The income is paid by, or on behalf of, an employer who is not a U.S. resident, and
3. The income is not borne by a permanent establishment or a fixed base that the employer has in the United States.

These exemptions do not apply to directors' fees and similar payments received by a resident of Thailand for services performed outside of Thailand as a member of the board of directors of a company that is a resident of the United States.

These exemptions do not apply to income residents of Thailand receive for performing services in the United States as entertainers (such as theater, motion picture, radio, or television artists, musicians) and athletes, if the income is more than $100 a day or $3,000 for the tax year. Regardless of these limits, income of Thai entertainers is exempt from U.S. tax if their visit to the United States is substantially supported by public funds of Thailand or its poilitical subdivisions or local authorities.

Pay received by employees of a ship or aircraft operated in international traffic by a Thai enterprise may be taxed by Thailand.

Trinidad and Tobago

Income (including reimbursed travel expenses) that residents of Trinidad and Tobago receive during the tax year for personal services performed in the United States is exempt from U.S. income tax if the individuals are in the United States for no more than 183 days during the tax year and either:

1. The residents are employees of a resident of a country other than the United States or are employees of a permanent establishment of a U.S. resident outside the United States and the income is not deducted in figuring the profits of a permanent establishment in the United States, or
2. The income is not more than $3,000 (excluding reimbursed travel expenses).

These exemptions do not apply to the professional earnings of public entertainers such as actors, musicians, and professional athletes or to any person providing their services if the pay is more than $100 per day (excluding reimbursed travel expenses).

Pay received by members of the regular complement of a ship or aircraft operated in international traffic by a resident of Trinidad and Tobago is exempt from U.S. tax.

Tunisia

Income that residents of Tunisia receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States are exempt from U.S. income tax if:

1. They are in the United States for no more than 183 days during the tax year,
2. They do not have a fixed base regularly available in the United States for performing the services, and
3. The gross income for the tax year from U.S. residents for services performed in the United States is no more than $7,500.

If they do not meet condition (2), they are taxed on the income that is attributable to the fixed base.

Income that residents of Tunisia receive for personal services performed in the United States as employees (dependent personal services) is exempt from U.S. income tax if:

1. The residents are in the U.S. for no more than 183 days during the tax year,
2. Their income is paid by, or on behalf of, an employer who is not a resident of the United States, and
3. Their income is not borne by a permanent establishment or fixed base the employer has in the United States.

Pay received by employees who are members of the regular complement of a ship or aircraft operated by an enterprise in international traffic is exempt from U.S. tax if the place of management of the enterprise is in Tunisia.

These exemptions do not apply to income residents of Tunisia receive as public entertainers (such as theater, motion picture, radio, or television artists and musicians) or athletes if their gross receipts, including reimbursed expenses, are more than $7,500 during the tax year.

These exemptions do not apply to fees received by a resident of Tunisia for services performed as a director of a U.S. corporation if the fees are treated as a distribution of profits and cannot be taken as a deduction by the corporation.

Turkey

Income that residents of Turkey receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States is exempt from U.S. income tax if the residents:

1. Are in the United States for purposes of performing the services or activities for no more than 183 days in any 12-month period, and
2. Do not have a fixed base regularly available to them in the United States for performing the services.

If they have a fixed base available, they are taxed only on income attributable to the fixed base.

Income that residents of Turkey receive for services performed in the United States as employees (dependent personal services) is exempt from U.S. income tax if the following requirements are met:

1. The resident is in the United States for no more than 183 days in any 12-month period,
2. The income is paid by, or on behalf of, an employer who is not a U.S. resident, and
3. The income is not borne by a permanent establishment or a fixed base that the employer has in the United States.

These exemptions do not apply to directors' fees and similar payments received by a resident of Turkey for services provided in the United States as a member of the board of directors of a company that is a resident of the United States.

These exemptions do not apply to income residents of Turkey receive as public entertainers (such as theater, motion picture, radio, or television artists, or musicians) or athletes if their gross receipts are more than $3,000 during the tax year for their entertainment activities in the United States. If their visit to the United States is substantially supported by a Turkish non-profit organization or from the public funds of Turkey, its political subdivisions, or local authorities, the income is taxed as independent personal services or dependent personal services.

These exemptions do not apply to a resident of Turkey who performs services as a member of the regular complement of a ship or an aircraft operated by a United States resident in international traffic.

United Kingdom

Income that residents of the United Kingdom receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States during the tax year is exempt from U.S. tax if the residents:

1. Are in the United States for no more than 183 days during the tax year, and
2. Do not have a fixed base regularly available in the United States.

Income that residents of the United Kingdom receive for labor or personal services performed in the United States as employees (dependent personal services) is exempt from U.S. tax if the employees meet three requirements:

1. They are in the United States for no more than 183 days,
2. Their income is paid by or on behalf of an employer who is not a resident of the United States, and
3. Their income is not borne by a permanent establishment or a fixed base that the employer has in the United States.

Income for services performed by an employee and member of the regular complement of a ship or aircraft operated in international traffic is taxed by the country of which the employer operating the ship or aircraft is a resident.

These exemptions do not apply to income received for services performed in the United States as an entertainer, musician, or athlete if the income, including reimbursed expenses, is more than $15,000 in any tax year.

Venezuela

Income that residents of Venezuela receive for personal services as independent contractors or self-employed individuals (independent personal services) in the United States is exempt from U.S. income tax if they do not have a fixed base regularly available to them in the United States for performing the services. If they have a fixed base available, they are taxed on the income attributable to the fixed base.

Income that residents of Venezuela receive for services performed in the United States as employees (dependent personal services) is exempt from U.S. income tax if the residents meet the following requirements:

1. They are in the United States for no more than 183 days in any 12-month period beginning or ending in the tax year,
2. Their income is paid by, or on behalf of, an employer who is not a U.S. resident, and
3. The income is not borne by a permanent establishment or a fixed base that the employer has in the United States.

These exemptions do not apply to directors' fees and similar payments received by a resident of Venezuela for services performed in the United States as a member of the board of directors of a company resident in the United States.

Pay received by a resident of Venezuela for services performed as an employee of a ship or an aircraft operated in international traffic is exempt from U.S. income tax.

These exemptions do not apply to income residents of Venezuela receive as public entertainers (such as theater, motion picture, radio, or television artists, or musicians) or sportsmen if their gross income, including reimbursed expenses, is more than $6,000 for their personal activities in the United States during the tax year. Regardless of these limits, income of Venezuelan entertainers or athletes is exempt from U.S. income tax if their visit to the United States is wholly or mainly supported by public funds of Venezuela, its political subdivisions, or local authorities.

Professors, Teachers, and Researchers

Pay of professors and teachers who are residents of the following countries is generally exempt from U.S. income tax for 2 or 3 years if they temporarily visit the United States to teach or do research. The exemption applies to pay earned by the visiting professor or teacher during the applicable period. For most of the following countries, the applicable period begins on the date of arrival in the United States for the purpose of teaching or engaging in research. Furthermore, for most of the following countries, the exemption applies even if the stay in the United States extends beyond the applicable period.

The exemption generally applies to pay received during a second teaching assignment if both are completed within the specified time, even if the second assignment was not arranged until after arrival in the United States on the first assignment. For each of the countries listed, the conditions are stated under which the pay of a professor or teacher from that country is exempt from U.S. income tax.

If you do not meet the requirements for exemption as a teacher or if you are a resident of a treaty country that does not have a special provision for teachers, you may qualify under a personal services income provision discussed earlier.

Austria

There is no special provision for professors or teachers.

Former treaty. For 1999, you can elect to apply the old treaty in its entirety. The provision for teaching is as follows.

A professor or teacher who is a resident of Austria and temporarily visits the United States to teach at a university, college, school, or other educational institution for not longer than 2 years is exempt from U.S. income tax on the income for teaching during that period.

Belgium

An individual who is a resident of Belgium on the date of arrival in the United States and who is temporarily in the United States at the invitation of the U.S. Government, a university, or other recognized educational institution in the United States primarily to teach or engage in research, or both, at a university or other accredited educational institution is exempt from U.S. income tax on income for the teaching or research for a maximum of 2 years from the date of arrival in the United States.

This exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

China, People's Republic of

An individual who is a resident of the People's Republic of China and who is temporarily in the United States primarily to teach, lecture, or conduct research at a university or other accredited educational institution or scientific research institution is exempt from U.S. income tax on income for the teaching, lecturing, or research for a total of not more than 3 years.

This exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

Commonwealth of Independent States

An individual who is a resident of a C.I.S. member on the date of arrival in the United States and who is temporarily in the United States at the invitation of the U.S. Government or an educational or scientific research institution in the United States primarily to teach, engage in research, or participate in scientific, technical, or professional conferences is exempt from U.S. income tax on income for teaching, research, or participation in these conferences for a maximum period of 2 years.

This exemption does not apply to income from research carried on mainly for the benefit of a private person, including a commercial enterprise of the United States or a foreign trade organization of a C.I.S. member.

The exemption does, however, apply if the research is conducted through an intergovernmental agreement on cooperation.

This exemption also applies to journalists and correspondents who are temporarily in the United States for periods not longer than 2 years and who receive their compensation from abroad. It is not necessary that the journalists or correspondents be invited by the U.S. Government or other appropriate institution, nor does it matter that they are employed by a private person, including commercial enterprises and foreign trade organizations.

Czech Republic

An individual is exempt from U.S. income tax on income for teaching or research for up to 2 years if he or she:

1. Is a resident of the Czech Republic immediately before visiting the United States, and
2. Is in the United States primarily to teach or conduct research at a university, college, school, or other accredited educational or research institution.

A Czech resident is entitled to these benefits only once. However, the exemption does not apply if:

1. The resident claimed during the immediate preceding period the benefits described later under Students and Apprentices, or
2. The income is from research undertaken primarily for the private benefit of a specific person or persons.

Denmark

A professor or teacher who is a resident of Denmark and temporarily visits the United States to teach at a university, college, school, or other educational institution for a period not longer than 2 years is exempt from U.S. income tax on income for teaching during that period.

Egypt

An individual who is a resident of Egypt on the date of arrival in the United States and who is temporarily in the United States primarily to teach or engage in research, or both, at a university or other recognized educational institution is exempt from U.S. income tax on income from the teaching or research for a maximum of 2 years from the date of arrival in the United States. The individual must have been invited to the United States for a period not expected to be longer than 2 years by the U.S. government or a state or local government, or by a university or other recognized educational institution in the United States.

This exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

France

An individual who is a resident of France on the date of arrival in the United States and who is temporarily in the United States at the invitation of the U.S. Government, a university, or other recognized educational or research institution in the United States primarily to teach or engage in research, or both, at a university or other educational or research institution is exempt from U.S. income tax on income from teaching or research for a maximum of 2 years from the date of arrival in the United States.

An individual may claim this benefit only once. Also, this benefit and the benefits described later under Students and Apprentices, can be claimed for no more than 5 years.

This exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

Germany

A professor or teacher who is a resident of Germany and who is in the United States for not more than 2 years to engage in advanced study or research or teaching at an accredited educational institution or institution engaged in research for the public benefit is exempt from U.S. tax on income received for such study, research, or teaching. If the individual's visit to the United States exceeds 2 years, the exemption is lost for the entire visit unless the competent authorities of Germany and the United States agree otherwise.

The exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

Greece

A professor or teacher who is a resident of Greece and who is temporarily in the United States to teach at a university, college, or other educational institution for a maximum of 3 years is exempt from U.S. income tax on the income received for teaching during that period.

Hungary

An individual who is a resident of Hungary on the date of arrival in the United States and who is temporarily in the United States primarily to teach or engage in research, or both, at a university or other recognized educational institution is exempt from U.S. income tax on income for the teaching or research for a maximum of 2 years from the date of arrival in the United States. The individual must have been invited to the United States for a period not expected to be longer than 2 years by the U.S. Government or a state or local government, or by a university or other recognized educational institution in the United States.

The exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

Iceland

An individual who is a resident of Iceland on the date of arrival in the United States and who is temporarily in the United States at the invitation of the U.S. Government, a university, or other recognized educational institution in the United States primarily to teach or engage in research, or both, at a university or other educational institution is exempt from U.S. income tax on income for the teaching or research for a maximum of 2 years from the date of arrival in the United States.

This exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

India

An individual is exempt from U.S. tax on income received for teaching or research if he or she:

1. Is a resident of India immediately before visiting the United States, and
2. Is in the United States to teach or engage in research at an accredited university or other recognized educational institution in the United States for a period not longer than 2 years.

If the individual's visit to the United States exceeds 2 years, the exemption is lost for the entire visit.

This exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

Indonesia

An individual is exempt from U.S. tax on income for teaching or research for a maximum of 2 years from the date of arrival in the United States if he or she:

1. Is a resident of Indonesia immediately before visiting the United States, and
2. Is in the United States at the invitation of a university, school, or other recognized educational institution to teach or engage in research, or both, at that educational institution.

A resident of Indonesia is entitled to this exemption only once. But this exemption does not apply to income from research carried on mainly for the private benefit of any person.

Israel

An individual who is a resident of Israel on the date of arrival in the United States and who is temporarily in the United States primarily to teach or engage in research, or both, at a university or other recognized educational institution is exempt from U.S. income tax on income from the teaching or research for a maximum of 2 years from the date of arrival in the United States. The individual must have been invited to the United States for a period not expected to be longer than 2 years by the U.S. Government or a state or local government, or by a university or other recognized educational institution in the United States.

This exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest. The exemption does not apply if, during the immediately preceding period, the benefits described in Article 24(1) of the treaty, pertaining to students, were claimed.

Italy

A professor or teacher who is a resident of Italy on the date of arrival in the United States and who temporarily visits the United States to teach or conduct research at a university, college, school, or other educational institution, or at a medical facility primarily funded from government sources, is exempt from U.S. income tax for up to 2 years on pay from this teaching or research.

This exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

Jamaica

An individual who is a resident of Jamaica on the date of arrival in the United States and who temporarily visits the United States to teach or engage in research at a university, college, or other recognized educational institution is exempt from U.S. income tax on the income received for the teaching or research for not more than 2 years from the date of arrival in the United States. A resident of Jamaica is entitled to this exemption only once.

This exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

Japan

An individual who is a resident of Japan on the date of arrival in the United States and who is temporarily in the United States at the invitation of the U.S. Government, a university, or other accredited educational institution located in the United States primarily to teach or engage in research, or both, at a university or other educational institution is exempt from U.S. income tax on income for the teaching or research for a maximum of 2 years from the date of arrival in the United States.

This exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

Korea, Republic of

An individual who is a resident of the Republic of Korea on the date of arrival in the United States and who is temporarily in the United States primarily to teach or engage in research, or both, at a university or other recognized educational institution is exempt from U.S. income tax on income for the teaching or research for a maximum of 2 years from the date of arrival in the United States. The individual must have been invited to the United States for a period not expected to be longer than 2 years by the U.S. Government or a state or local government, or by a university or other recognized educational institution in the United States.

The exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

Luxembourg

A resident of Luxembourg who is temporarily in the United States at the invitation of a U.S. university, college, school, or other recognized educational institution only to teach or engage in research, or both, at that educational institution is exempt from U.S. income tax on income for the teaching or research for not more than 2 years from the date of arrival in the United States.

This exemption does not apply to pay for research carried on for the benefit of any person other than the educational institution that extended the invitation.

Netherlands

An individual is exempt from U.S. income tax on income received for teaching or research for a maximum of 2 years from the date of arrival if he or she:

1. Is a resident of the Netherlands immediately before visiting the United States, and
2. Is in the United States to teach or engage in research at a university, college, or other recognized educational institution for not more than 2 years.

If the individual's visit to the United States is longer than 2 years, the exemption is lost for the entire visit unless the competent authorities of the Netherlands and the United States agree otherwise.

The exemption does not apply to income from research carried on primarily for the private benefit of any person rather than in the public interest. Nor does the exemption apply if the resident claimed during the immediate preceding period the benefits described later under Students and Apprentices.

Norway

An individual who is a resident of Norway on the date of arrival in the United States and who is temporarily in the United States at the invitation of the U.S. Government, a university, or other recognized educational institution in the United States primarily to teach or engage in research, or both, at a university or other recognized educational institution is exempt from U.S. income tax on income for the teaching or research for a maximum period of 2 years from the date of arrival in the United States.

This exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

Pakistan

A professor or teacher who is a resident of Pakistan and who temporarily visits the United States to teach at a university, college, school, or other educational institution for not longer than 2 years is exempt from U.S. income tax on the income received for teaching for that period.

Philippines

An individual who is a resident of the Philippines on the date of arrival in the United States and who is temporarily in the United States primarily to teach or engage in research, or both, at a university or other recognized educational institution is exempt from U.S. income tax on income from the teaching or research for not more than 2 years from the date of arrival in the United States. The individual must have been invited to the United States for a period not expected to be longer than 2 years by the U.S. Government or a state or local government, or by a university or other recognized educational institution in the United States.

This exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

Poland

An individual who is a resident of Poland on the date of arrival in the United States and who is temporarily in the United States at the invitation of the U.S. Government, a university, or other recognized educational institution in the United States primarily to teach or engage in research, or both, at a university or other recognized educational institution is exempt from U.S. income tax on income for the teaching or research for a maximum of 2 years from the date of arrival in the United States.

This exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

Portugal

An individual who is a resident of Portugal on the date of arrival in the United States and who is temporarily in the United States at the invitation of the U.S. Government, a university, other accredited educational institution, or recognized research institution in the United States, or under an official cultural exchange program, only to teach or engage in research, or both, at a university or educational institution is exempt from U.S. income tax on income from teaching or research for a maximum of 2 years from the date of arrival in the United States. An individual is entitled to these benefits only once. However, these benefits, and the benefits described later under Students and Apprentices cannot be claimed either simultaneously or consecutively.

This exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

Romania

An individual who is a resident of Romania on the date of arrival in the United States and who is temporarily in the United States at the invitation of the U.S. Government, a university, or other recognized educational institution in the United States primarily to teach or engage in research, or both, at a university or other recognized educational institution is exempt from U.S. income tax on income for the teaching or research for a maximum of 2 years from the date of arrival in the United States.

This exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

Slovak Republic

An individual is exempt from U.S. income tax on income for teaching or research for up to 2 years if he or she:

1. Is a resident of the Slovak Republic immediately before visiting the United States, and
2. Is in the United States primarily to teach or conduct research at a university, college, school, or other accredited educational or research institution.

A Slovak resident is entitled to these benefits only once. However, the exemption does not apply if:

1. The resident claimed during the immediate preceding period the benefits described later under Students and Apprentices, or
2. The income is from research undertaken primarily for the private benefit of a specific person or persons.

Thailand

An individual who is a resident of Thailand on the date of arrival in the United States and who is in the United States for not longer than 2 years primarily to teach or engage in research at a university, college, school, or other recognized educational institution is exempt from U.S. income tax on income for the teaching or research. The exemption from tax applies only if the visit does not exceed two years from the date the individual first visits the United States for the purpose of engaging in teaching or research.

This exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest. This exemption does not apply if, during the immediately preceding period, the benefits described in treaty Article 22(1), pertaining to students, were claimed.

Trinidad and Tobago

An individual who is a resident of Trinidad and Tobago on the date of arrival in the United States and who is temporarily in the United States at the invitation of the U.S. Government, a university, or other accredited educational institution in the United States primarily to teach or engage in research, or both, at a university or other accredited educational institution is exempt from U.S. income tax on the income received for the teaching or research for a maximum of 2 years from the date of arrival in the United States.

This exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest. Nor does the exemption apply to income if an agreement exists between the Governments of Trinidad and Tobago and the United States for providing the services of these individuals.

Turkey

An individual who was a resident of Turkey immediately before visiting the United States who is in the United States for not longer than 2 years for the purpose of teaching or engaging in scientific research is exempt from U.S. income tax on payments received from outside the United States for teaching or research.

United Kingdom

A professor or teacher who is a resident of the United Kingdom on the date of arrival in the United States and who is in the United States for not longer than 2 years primarily to teach or engage in research at a university, college, or other recognized educational institution is exempt from U.S. income tax on income for the teaching or research. If the individual's 2-year period is exceeded, the exemption is lost for the entire visit, including the 2-year period.

The exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

Venezuela

An individual who is a resident of Venezuela on the date of arrival in the United States and who temporarily visits the United States to teach or engage in research at a recognized educational or research institution is exempt from U.S. income tax on the income received for the teaching or research for not more than 2 years from the date of arrival in the United States. This benefit can be claimed for no more than 5 years.

The exemption does not apply to income from research carried on mainly for the private benefit of any person rather than in the public interest.

Students and Apprentices

Residents of the following countries who are in the United States to study or acquire technical experience are exempt from U.S. income tax, under certain conditions, on amounts received from abroad for their maintenance and studies.

This exemption does not apply to the salary paid by a foreign corporation to one of its executives, a citizen and resident of a foreign country who is temporarily in the United States to study a particular industry for an employer. That amount is a continuation of salary and is not received to study or acquire experience.

For each country listed there is a statement of the conditions under which the exemption applies to students and apprentices from that country.

Amounts received from the National Institutes of Health (NIH) under provisions of the Visiting Fellows Program are generally treated as a grant, allowance, or award for purposes of whether an exemption is provided by treaty. Amounts received from NIH under the Visiting Associate Program and Visiting Scientist Program are not exempt from U.S. tax as a grant, allowance, or award.

Australia

A resident of Australia or an individual who was a resident of Australia immediately before visiting the United States who is temporarily here for full-time education is exempt from U.S. income tax on payments received from outside the United States for the individual's maintenance or education.

Austria

A student, apprentice, or business trainee who is a resident of Austria immediately before visiting the United States and is in the United States for the purpose of full-time education at a recognized educational institution or full-time training is exempt from U.S. income tax on amounts received from sources outside the United States for the individual's maintenance, education, or training.

Apprentices and business trainees are entitled to the benefit of this exemption for a maximum period of 3 years.

Former treaty. For 1999, you can elect to apply the old treaty in its entirety. The provisions for students and apprentices are as follows.

A resident of Austria who is temporarily in the United States only as a student at a university, college, school, or other educational institution is exempt from U.S. income tax on amounts received from abroad for study and maintenance. An apprentice (including Volontaere and Praktikanten) who is a resident of Austria and is temporarily in the United States only to acquire business or technical experience is also exempt from U.S. income tax on amounts received from abroad for study and maintenance.

A resident of Austria who receives a grant, allowance, or award from a nonprofit religious, scientific, literary, or educational organization is exempt from U.S. income tax on the payments from that organization. Pay for personal services is not exempt.

A resident of Austria who is an employee of an Austrian enterprise, or an organization of the kind mentioned in the preceding paragraph, is exempt from U.S. income tax on pay from abroad paid by that enterprise or organization if:

1. The individual is temporarily in the United States for no more than one year only to acquire technical, professional, or business experience from any person other than the enterprise or organization by which employed, and
2. The annual income for services, wherever performed, is not more than $10,000.

Barbados

A student or business apprentice who is a resident of Barbados on the date of arrival in the United States and is here for full-time education or training is exempt from U.S. income tax on payments received from outside the United States for the individual's maintenance, education, or training.

Nevertheless, an individual who qualifies for this exemption may instead choose to be treated as a resident alien of the United States for all U.S. income tax purposes. Once made, this choice applies for the entire period that the individual remains qualified for exemption and may not be revoked without the permission of the U.S. competent authority.

Belgium

An individual who is a resident of Belgium on the date of arrival in the United States and who is temporarily in the United States primarily to study at a university or other recognized educational institution in the United States, obtain professional training, or study or do research as a recipient of a grant, allowance, or award from a governmental, religious, charitable, scientific, literary, or educational organization is exempt from U.S. income tax on the following amounts:

1. Gifts from abroad for maintenance, education, study, research, or training,
2. The grant, allowance, or award, and
3. Income from personal services performed in the United States of up to $2,000 for each tax year.

An individual is entitled to the benefit of this exemption for a maximum of 5 years.

An individual who is a resident of Belgium on the date of arrival in the United States and who is in the United States as an employee of, or under contract with, a resident of Belgium is exempt from U.S. income tax for a period of 12 consecutive months on up to $5,000 received for personal services if the individual is in the United States primarily to:

1. Acquire technical, professional, or business experience from a person other than that resident of Belgium or other than a person related to that resident, or
2. Study at an educational institution.

An individual who is a resident of Belgium on the date of arrival in the United States and who is temporarily present in the United States for not longer than one year as a participant in a program sponsored by the U.S. Government primarily to train, research, or study is exempt from U.S. income tax on income received for personal services for the training, research, or study in the amount of $10,000.

Canada

A full-time student, trainee, or business apprentice who is or was a Canadian resident immediately before visiting the United States is exempt from U.S. income tax on amounts received from sources outside the United States for maintenance, education, or training.

Also see Publication 597, Information on the United States--Canada Income Tax Treaty.

China, People's Republic of

A student, business apprentice, or trainee who is a resident of the People's Republic of China on the date of arrival in the United States and who is present in the United States solely to obtain training, education, or special technical experience is exempt from U.S. income tax on the following amounts:

1. Payments received from abroad for maintenance, education, study, research, or training,
2. Grants or awards from a government, scientific, educational, or other tax-exempt organization, and
3. Income from personal services performed in the United States of up to $5,000 for each tax year.

An individual is entitled to this exemption only for the time reasonably necessary to complete the education or training.

Commonwealth of Independent States

An individual who is a resident of a C.I.S. member and who is temporarily in the United States primarily to study at an educational or scientific research institution or to obtain training for qualification in a profession or specialty is exempt from U.S. income tax on amounts received as stipends, scholarships, or other substitute allowances necessary to provide ordinary living expenses. An individual is entitled to the benefit of this exemption for a maximum of 5 years and for less than $10,000 in each tax year.

An individual who is a resident of a C.I.S. member and who is temporarily in the United States primarily to acquire technical, professional, or commercial experience or perform technical services and who